3170-XXXX SS ROADS (30-day FRN) FINAL

CONSUMER FINANCIAL PROTECTION BUREAU
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A
ROADS TO FINANCIAL INDEPENDENCE
(OMB CONTROL NUMBER: 3170-00xx)

OMB TERMS OF CLEARANCE: Not applicable. This is a new information collection
request.

NOTE TO REVIEWERS: ROADS to Financial Independence project was formerly called
“Bridges to Financial Security: A Multi-site Demonstration Project”.

ABSTRACT: The Consumer Financial Protect Bureau (CFPB), beginning in 2015, will launch a
multi-site financial education demonstration project to provide one-on-one and group financial
counseling/coaching services to individuals with disabilities transitioning into the workplace or
already employed. The goal is twofold: 1) to improve the financial skills of approximately
15,000 individuals across the spectrum of disability to effectively navigate the financial
marketplace, resulting in improved credit, reduced debt, and increased savings; and 2) to build
the capacity of diverse multi-sector systems (non-disability and disability) in up to 14 cities to
unite around the common purpose of building financial security for individuals with disabilities.

1

CFPB envisions the need to collect a combination of client personally identifiable information
(PII), including direct-identifying PII (i.e., basic contact and demographic information),
performance metrics (outputs), as well as other relevant organization-level outcomes. Monthly
qualitative reports and quantitative aggregated individual data will be collected from
participating sites to document the design, growth and impact of up to 14 integrated diverse
delivery models serving primarily low-income populations with disabilities.

PART A.

JUSTIFICATION

1. Circumstances Necessitating the Data collection
The Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd Frank Act”),
Public Law 111203, established the Consumer Financial Protection Bureau (“CFPB” or the
“Bureau”) to regulate the offering and provision of consumer products or services under federal
consumer financial laws. Consistent with the purposes of the Dodd Frank Act, the CFPB mission
is to help consumer finance markets work by making rules more effective, by consistently and
fairly enforcing those rules, and by empowering consumers to take more control over their
economic lives.

Section 1013(d)(2) of the Dodd Frank Act mandates that the Bureau provide opportunities for
consumers to access a range of financial activities, including savings and wealth building,
financial counseling (including community-based counseling), and information to better
understand credit products and credit histories. Additionally, Section 1013(b)(2) states that a unit
shall be established whose function includes providing “information, guidance, and technical

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assistance regarding the offering and provision of consumer financial products to traditionally
underserved consumers and communities”.

The Office of Financial Empowerment at CFPB interprets these provisions as the foundation for
our vision to serve low-income and economically vulnerable consumers, including individuals
with disabilities who face unique challenges in meeting their financial needs in the marketplace.
The Office of Financial Empowerment is interested in identifying approaches to support the
financial capability of individuals with disabilities transitioning into the workforce or reentering
the workforce after a period of time.

People with disabilities comprise 12 – 19 percent of the U.S. population 1 and experience
significant disparities in employment and participation in the labor force. The employment rate
for people with disabilities may be low due to lower educational attainment, individual and
systemic barriers to employment, and discrimination. Among those who do work, people with
disabilities, on average, earn about $10,000 2 less than people without disabilities. The poverty
rate of people with disabilities is more than double the rate of those without disabilities. 3 These
economic disparities are further exacerbated by higher costs associated with living with a
disability. The material conditions, including economic hardship, of people with disabilities may
inhibit access to high quality of life and well-being. Economic hardships have also been linked to

1

Conroy, N.D., McDonald, K.E., Morris, M., & Jennings, E. (2014). Financial Capability of Adults with
Disabilities. Findings from the FINRA Investor Education Foundation 2012 National Financial Capability Study.
2
StatsRRTC, “Annual disability statistics compendium”, (2013), http://disabilitycompendium.org/compendiumstatistics/earnings.
3
Ibid.
3

significant negative health outcomes, ranging from an increased risk of depression or mental
illness to an increased risk in mortality. 4

The positive financial or tax situation of an individual with disabilities transitioning into the
workforce or reentering the workforce after a period, such as good credit or receipt of the Earned
Income Tax Credit, often contributes to successful placement and stability on the job. However,
data indicate that people with disabilities have less overall financial capability compared to other
Americans. 5 The National Disability Institute examined the FINRA Investor Education
Foundation 2012 National Financial Capability Study and found, among other things, that people
with disabilities reported greater difficulty in covering monthly expenses and lower financial
literacy and were less likely to have rainy day funds set aside and more likely to carry credit card
balances 6. Further, the first ever reports produced by the IRS in 2007 7 and 2010 8 on the
characteristics and profile of taxpayers with disabilities highlighted multiple discrepancies, such
as “1.3 to 1.6 more tax returns could be filed from working disabled residents ages 18 to 59” and

4

Organization for Economic Co-Operation and Development (OECD). “Well-being and the global financial crisis”,
http://www.keepeek.com/Digital-Asset-Management/oecd/economics/how-s-life-2013 /well-being-and-the-globalfinancial-crisis_how_life-2013-7-en#page25.
5
Conroy, N.D., McDonald, K.E., Morris, M., & Jennings, E. (2014). Financial Capability of Adults with
Disabilities. Findings from the FINRA Investor Education Foundation 2012 National Financial Capability Study p. 7
(noting that respondents were identified as having disabilities if they selected “permanently sick, disabled, or unable
to work” in response to the study’s question on work status).
6
Conroy, N.D., McDonald, K.E., Morris, M., & Jennings, E. (2014). Financial Capability of Adults with
Disabilities. Findings from the FINRA Investor Education Foundation 2012 National Financial Capability Study p. 7
(noting that respondents were identified as having disabilities if they selected “permanently sick, disabled, or unable
to work” in response to the study’s question on work status).
7
Disabilities Research Report Characteristics of Disabled Taxpayers Ages 18 to 59: Study of Filing Patterns and
Preferences for Receiving Tax information & Services Internal Revenue Service Publication 4640 (10-2007).
Catalog Number 50912H Department of Treasury Internal Revenue Service www.irs.gov.
8
Taxpayers with Disabilities 2010 IRS report Prepared for Stakeholder Partnerships, Education and Communication.
Wage & Investment Research & Analysis September 2010. Publication 4640 (Rev.9-2010) Catalog Number 50912H
Department of the Treasury Internal Revenue Service. www.irs.gov.
4

the need to make tax software readily accessible. 9 The IRS surveys found that the majority of
taxpayers with disabilities reported incomes less than $20,000, yet despite the low Adjusted
Gross Income, over 60 percent reported using paid tax professionals to prepare their most recent
tax returns. 10

Additionally, the most economically vulnerable consumers, of whom persons with disabilities
are frequently numbered, are part of the “traditionally underserved consumers and communities.”
These persons are typically the hardest to reach and the most difficult to serve. This necessitates
in person, individualized guidance delivered at a trusted, convenient, and accessible location.

This first-of-its kind pilot seeks to determine and demonstrate the value of imbedding financial
capability services in existing service delivery networks, both providing free financial
counseling/coaching and disability services to individuals with disabilities. The data collection is
necessary to help CFPB understand the effectiveness of the approaches and delivery model used
in this project.

2. Use of the Information
The purpose of the demonstration is to integrate financial capability services into existing service
delivery systems to improve the problem of financial insecurity for individuals with disabilities.
The goal is twofold: 1) to improve the financial skills of over 15,000 individuals across the

9

Disabilities Research Report Characteristics of Disabled Taxpayers Ages 18 to 59: Study of Filing Patterns and
Preferences for Receiving Tax information & Services Internal Revenue Service Publication 4640 (10-2007).
Catalog Number 50912H Department of Treasury Internal Revenue Service www.irs.gov. p.32
10
Taxpayers with Disabilities 2010 IRS report Prepared for Stakeholder Partnerships, Education and
Communication. Wage & Investment Research & Analysis September 2010. Publication 4640 (Rev.9-2010) Catalog
Number 50912H Department of the Treasury Internal Revenue Service. www.irs.gov.
5

spectrum of disability to make more informed financial decisions and effectively navigate the
financial marketplace resulting in improved credit, reduced debt, and increased savings; and 2) to
build the capacity of diverse multi-sector systems (non-disability and disability) in up to 14 cities
to unite around the common purpose of building financial security for individuals with
disabilities.

In order to understand the individual and organizational impact of the program, CFPB envisions
the need to collect a combination of client personal information (i.e., basic contact and
demographic information), performance metrics (outputs), as well as other relevant organizationlevel outcomes.

A developmental evaluation that utilizes the client information, performance metrics and
organization-level outcomes will document the design, growth and impact of up to 14 integrated
diverse delivery models that serve primarily low-income populations with disabilities.
The instrument that the coaches will use to gather individual data is attached to this
submission. The information collected includes demographic information, employment status,
financial information, receipt of public benefits, and financial behaviors, habits, attitudes and
skills. The instrument includes questions from the FINRA Investor Education Foundation’s
National Financial Capability study, which is can be found here,
http://www.usfinancialcapability.org/about.php According to FINRA this study was developed
in consultation with the U.S. Department of the Treasury, other federal agencies and President
Obama's Advisory Council on Financial Capability, and the overarching research objectives are
to benchmark and measure key indicators of financial capability and evaluate how these

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indicators vary with underlying demographic, behavioral, attitudinal and financial literacy
characteristics. Using these indicators for which there is nationally representative data will
enable coaches to have an enhanced understanding of their clients’ financial capability.

This may include the accompanying Self-Sufficiency Matrix, which will be used to track a
customer’s progress over time, based on his or her area of focus. This matrix is a modified
version of the Arizona Self-Sufficiency Matrix, which has been used a basis for evaluating
outcomes in other social services programs across the country. 11 These questions support the
main strategy of the ROADS project, which is to integrate financial capability services into
existing programs that serve people with disabilities. As a result, the categories in the matrix are
intended to capture the complexity and interconnectedness of family and community support in
the financial stability of people with disabilities. The breadth of the questions will allow
customers with disabilities who seek services in these organizations to identify and discuss a
range of their current financial barriers and solicit help from their coaches in getting appropriate
services from the host organization or referrals to other community groups.
Some of the questions and information requested through the financial assessment and follow-up
exercises may be of a sensitive nature. Additional justification for collecting the data can be
found in Section 11.

Clients, coaches, and supervisors would provide informed consent before participating in any
interview and/or survey. The client-level raw data will not be shared outside of the financial
11

See e.g. Omni Institute, Self-Sufficiency Matrix: An Assessment and Measurement Tool for Boulder County
Community Services and Housing Programs (June 2009), at
http://communityimpact.unitedwaycm.org/epledge/servlet/eAndar.WebExtDocument/313037/31/DenverStudy;
Greg White et al., TG 5 Sub-Group: Outcomes and Evaluation of Housing Models (no date), at
http://www.fairfaxcounty.gov/homeless/forums/presentations/outcomes-and-evaluations.pdf
7

coaches/counselors working with the clients and the CFPB contractor responsible for collecting
and analyzing the data. CFPB will not receive client-level raw data or any personally identifiable
information (PII), including direct-identifying PII. CFPB will receive and may choose to release
de-identified results and aggregated analyses of those results (such as trends in financial issues)
in public reports it will issue.

3. Use of Information Technology
Individual outcomes survey data will be collected and recorded by subcontractor staff via Social
Solutions Global, Inc. (SSG) software. SSG will host the service via a SSG-controlled Website.
SSG will provide help desk, error correction, and maintenance services for the Solution as per its
most-current published maintenance schedule

3a. Universal Access and Design
As part of the overall data collection process, and in accordance with applicable federal law
(American’s with Disabilities Act and Section 508 of the Rehab Act 12), all data collection tools,
disclosures will be made available in alternative formats. Additionally, any online data collection
tools will be 508 compliant.

4. Efforts to Identify Duplication
Some of the data points CFPB will be collecting from participants may already be collected if the
participants are regular clients within partnering disability organizations. CFPB will consult with
service providers to identify potential duplication of data collection to determine the utility of
12

American With Disabilities Act of 1990, 42 U.S.C. 12101; http://www.gpo.gove/fdsys/pkg/USCODE-2009 title42/htmlUSCODE-2009-title42-chap126.htm.
8

duplicating data already collected from the participants to ensure that unnecessary duplication
and undue burden does not occur for participants.

5. Efforts to Minimize Burdens on Small Entities
Not applicable. Respondents are participants in the ROADS demonstration project and,
therefore, no small entities are impacted by this collection of information.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
If the collection is not conducted, CFPB would not be able to know how the program is
performing nor would it know how to improve the program moving forward on behalf of
individuals with disabilities.

7. Circumstances Requiring Special Information Collection
There are no special circumstances. The proposed data collection of information is conducted in
a manner consistent with the guidelines in 5 CFR 1320.5 (d)(2).

8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice in the Federal
Register allowing the public 60 days to comment on this proposed new collection of information.
No comments were received in response to this notice. Further and in accordance with 5 CFR
1320.5(a)(1)(iv), the Bureau published a notice in the Federal Register allowing the public 30
days to comment on the submission of this information collection request to the Office of
Management and Budget.

9

In the process of developing the procurement for this program, CFPB consulted extensively with
people outside the Bureau.

Specifically, the Bureau released a public request for information (RFI) in late Fall 2013 to
solicit feedback from organizations, potential vendors, and experts. The RFI was sent to
hundreds of stakeholders working with individuals and families with disabilities, including
organizations serving these respective populations, experts in financial coaching, financial
counselors, and others. CFPB conducted outreach to several Federal agencies including, the IRS,
Department of Labor, Social Security, and others to learn more about the disability network and
understand the best way to deliver services to the respective populations. Further, prior to the
solicitation, the Bureau convened a two-day meeting in Washington, DC with over two dozen
key national disability leaders to understand existing financial services and products and needs.

9. Payments or Gifts to Respondents
No payment or gifts will be provided to respondents for the administrative data. No payments or
gifts will be provided to counselors/coaches or supervisor respondents for interview or survey
responses.

10. Assurances of Confidentiality
The Contractor is committed to securely collecting and using the private collected data under this
demonstration (i.e., financial assessment data, administrative and program data). The ROADS

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Demonstration will convene a respected advisory board of national disability and financial
capability experts to assist in the review and ongoing oversight of the project.

Individuals with disabilities will be informed of the nature of the demonstration and opportunity
to receive individual or group financial counseling/coaching, and how the information being
collected will be used. CFPB will market to individuals with disabilities through six separate
model/sites providing established financial counseling/coaching programs and disability benefits
training. Each site will advertise the availability of financial counseling/coaching services
through its marketing and communication collateral. The volunteer opportunity will be offered to
individuals with disabilities who may drop in to a location or make an appointment. Each
participate will be screened using the Financial Health Assessment Tool and Informed Consent.
Participants will then be asked to sign their permission to participate in the demonstration.

Reports produced under this demonstration will not include directly-identifying PII collected
during the demonstration. Additional PII, such as outcome data or program administrative data,
such as date of birth, will not be included in reports produced. CFPB will be given aggregate,
rolled up results, and all individual level data will be stripped of the direct identifiers. All Interim
and Final Reports and any presentations given on the demonstration will ensure that primary data
is aggregated to a level at which the individual identities of those who provided the information
could not reasonably be discerned.
At the time of initial meeting, a PRA and Privacy notice will be provided to the customer before
any assessment of information is collected. Information collected will be done in accordance
with the Privacy Act and as described in the Bureau’s System of Records Notice, CFPB.021 –

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Consumer Education and Engagement Records. A revised SORN was submitted to OMB in
December 2014 and is expected to be published shortly. Furthermore, the Bureau has published a
PIA, Consumer Education, which outlines how it will manage information collected as part of
this program. This PIA can be located on CFPB’s website at
http://files.consumerfinance.gov/f/201409_cfpb_consumer-education_pia.pdf .

11. Justification for Sensitive Questions
Financial counselors/coaches will collect direct-identifying Personally Identifiable Information
(PII) including name and basic contact information to facilitate participation in the counseling
program. In addition, coaches will collect non-direct identifying demographic data and
financial/benefits/disability data to understand the impact of the demonstration. Two pieces of
demographic data that may be collected include gender and citizenship. The purpose for
collecting these pieces of data are to enable the counselors/coaches to effectively serve each
client and tailor the programs around each client’s individual financial circumstances, goals,
knowledge and experiences with the financial system. If these characteristics impact the clients’
experiences or opportunities, it is important that the counselors/coaches have that information,
and can respond as appropriate. In addition, the CFPB needs to understand how these programs
impact consumers with different demographics or characteristics, to evaluate the program
effectiveness and make changes, as appropriate, to tailor programs to meet the needs of a range
of consumers.

Counselors/coaches specifically trained to pull and review credit (consumer) reports and scores
may collect other directly identifying information, including Social Security numbers (SSN) and
financial account information (credit reports), providing the individual with a disability
understands that providing this information is entirely voluntary and has read and signed
Financial Health Assessment Screening Tool and Informed Consent. Clients will also be given
the option to pull their credit reports themselves, which would eliminate the need for the
counselors/coaches to collect their SSN. Clients who choose not to provide their SSN, or who
choose not to pull or review their own credit report will not be kept from participating in the
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program. The choice to review one’s credit report and score is voluntary and does require that
the participant provide a SSN for that purpose only. Only the counselors pulling the credit
reports and scores will see that information. No SSN will be recorded into the demonstration data
collection. Only credit score numbers will be recorded and only at the request of the individual
requesting the credit pull. The only reason for pulling the credit score is to link other selfreported financial data and outcomes with credit bureau records. After the credit bureau
information is accessed and linked to self-reported outcome data, the documents containing the
SSNs will be destroyed. SSNs will not be used as an administrative identifier or tracking number
to aid in the delivery of services. An alternative identification number will be developed. SSNs
will not be collected as a normal course of action for program operation purposed.

All participation in the financial counseling/coaching project is optional. Sites will be required to
obtain informed consent to collect information from those who choose to participate. All
participants will be asked to complete a financial assessment intake form. All participating sites
and staff will take the necessary precautions to ensure that the information provided by
individuals will remain secure, as described in Section 10 above.

This is the first time that the collection and analysis of financial data (demographics, financial,
self-sufficiency and disability specific) of individuals with disabilities is being conducted on a
national scale. Information collected will help frame the needs of individuals with disabilities
and the systems serving them (state, non-profit or private) to:
1) understand the effectiveness and impact of the financial counseling/coaching models on
individual debt, credit and savings;
2) understand what community-based model and what channels of service delivery most
impact individuals with disabilities;
3) understand any unique factors that influence outcomes (role of Waivers, receipt of
means-tested benefits, asset limits for saving, and lack of access to traditional banking
services);
4) understand what model of financial education - group or one-on-one counseling/coaching
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is most popular with individuals with disabilities;
5) understand top five most popular financial goals set by individuals with disabilities;
6) understand which financial capability services are most frequently utilized and impact;
7) understand how six different site models worked and how well each is integrated into the
existing service delivery model overall to build scale and sustainability;
8) produce a series of briefs that document individual and systems impact;
9) produce a series of Playbooks for other partners in geographic areas to replicate the
disability inclusive model; and
10) inform the development of new curriculum and products specifically targeted for
individuals with disabilities.

12. Estimated Burden of Information Collection
It is estimated that approximately 15,000 respondents will complete the financial assessment,
which will take approximately thirty minutes. It is expected that a portion of respondents who
complete the financial assessment will participate in a subsequent individual financial counseling
session, in-person, follow-up appointment, and a later electronic financial assessment.

Estimate of Annualized Time Burden to Respondents (Total Project)
Information
Collection
Requirement

Number of
Respondents

Frequency

Total
Responses

Total
Burden
Hours

15,120

Avg.
Burden per
Response
(hours)
2.0

Financial Assessment

15,120

1

Creating Financial
Counseling (budget &
action plans)
In-person Follow-up
(credit report/bank
statement review)
Electronic Follow-up
(doc review, no
appointment)
Total

6,048

1

6,048

1.0

6,048

3,024

1

3,024

1.9

5,746

2,268

1

2,268

0.2

454

15,120*

///////

37,800

///////////////

42,488

30,240

*The estimated number of responses is 15,120. Respondents to Creating Financial Counseling, In-person Follow-up,
and Electronic Follow-up are a subset of those responding to the Financial Assessment.

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To estimate the value of the time invested by the respondents, an hourly wage of $10.90 was
used. This wage is representative of the current hourly 25% wage of all occupations available
from the Bureau of Labor Statistics 13

Estimate of Annualized Time Burden to Respondents (Total Project)
Information Collection
Requirement

Number of
Respondents

Total Burden
Hours

Avg. Hourly
Wage Rate

Total Cost
Burden

Financial Assessment

15,120

30,240

$ 10.90

$ 329,616

Recording Financial
Counseling (budget &
action plans)
In-person Follow-up
(credit report/bank
statement review)
Electronic Follow-up
(no appointment)

6,048

6,048

$ 10.90

$ 65,923

3,024

5,746

$ 10.90

$ 62,631

2,268

454

$ 10.90

$ 4,949

Total

15,120

42,488

//////////

$ 463,119

13. Estimated Total Annual Cost Burden to Respondents or Record-keepers
This collection of information will not result in any costs to respondents other than those costs
already captured above in Item 12.

14. Estimated Cost to the Federal Government

The estimated cost for this work is still to be determined. However, we estimate that CFPB will
need to cover the costs (via the contract) of a client management/outcome tracking system in

13

May 2013 National Occupational Employment and Wage Estimates, Bureau of Labor Statistics,
http://www.bls.gov/oes/current/oes_nat.htm, Accessed 9/11/2014.
15

order to be able to collect and report data, as well as costs associated with the collection,
analysis, and reporting of interview and survey data.

15. Program Changes or Adjustments
This is a new information collection request; therefore, the entire burden associated with this
collection of information is considered a program change.

16. Plans for Tabulation, Statistical Analysis, and Publication Timetable for Project
Demonstration Sites will provide CFPB with monthly qualitative and quantitative updates on the
individual site models and data collection to understand how, why and what is working. An
Interim and Final Year Report will provide CFPB with an analysis of the monthly data reports.
There are no scheduled publication timetables at this time.

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Timeline for Individual and Systems Evaluation
INDIVIDUAL DATA
Task
Receive OMB
Approval
Program enrollment
on a rolling basis for
at least five months of
treatments

Date
February 1, 2015

Administer Financial
Assessment Survey
and Collect Informed
Consent

Ongoing

Complete collection
and provide analysis
of administrative and
impact data
Complete Baseline
Year Report

July 31, 2015 –
August 31, 2015

March 1, 2015 –
July 31, 2015

September, 2015

PROGRAM SITE DATA
Task
Pre-Contract: Complete
site needs self-assessment
Pre Contract: Complete
analysis of selfassessment to establish
training and technical
assistance needs
Pre Contract:
Sites provide customer
flow information to
inform best intersections
for service delivery
Contract Period:
Monthly online reports to
share what is working
what is not
Contract Period:
Monthly aggregated data
reports uploaded to
ROADS portal and shared
with CFPB.

Date
October 2014
November 2014

December 2014

January 2015 – July
2015

March 2015 – July
2015

17. Display of Expiration Date
The Bureau plans to display the OMB control number expiration date for OMB approval of the
information collection on all data collection materials.

18. Exceptions to the Certification Requirement
The Bureau certifies that this collection of information is consistent with the requirements of 5
CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an exemption
to these certification requirements.

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